TRUST & SECURITY

PRIVACY

JOURNEY’s Policy

Journey Nudge Inc.

About Your Privacy and JOURNEY’s Privacy Policy

Your company and employee’s privacy is extremely important to us. We are constantly putting a great deal of thought, effort, tools, resources and procedures in place in order to protect and safeguard your privacy. This document is our “Privacy Policy” and it contains details on issues related to your privacy when using our services. This Privacy Policy applies to visitors to our public website and operated by Journey Nudge, the registered users of Journey Nudge’s associated mobile and web application (collectively with the websites, the “Tool”), to the organizations providing internal data (“Organization”) and to the coaches that provide the Coaching Services (“COACHES”). It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Tool.

The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, “we”, “our”, “us”, “Tool”, and “Coach Services”) have the same meaning as in our Terms and Conditions document. When you use our Tool you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Tool immediately or cease to provide the Coach Services, as applicable. By accessing and using our Tool, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.

The Privacy Policy does not apply to the collection and use of certain employment-related information. If you are a current or former Journey Nudge job applicant, employee, or contractor please contact us at [email protected] for the appropriate notice.

 Information Collection, Use, and Disclosure

Categories of Information Collected

To let us operate the Tool effectively and to let you use the Tool, including the Services, we may collect, use, and store the information described below. We do not disclose information to third parties, as described further below. The information we collect is received directly from you and generated in the course of your use of the Tool. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

Visitor Data: Journey Nudge, Inc. collects, uses, and stores data regarding user visits to its website and use of the Journey Nudge, Inc. application (“Visitor Data”), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the Journey Nudge, Inc. pages, and information about the browser or device used to access the website and application..

Onboarding Data: In addition to the questionnaire responses provided by users (including Coaches and Organizations) in the process of initial registration, Journey Nudge, Inc. collects, uses, and stores certain additional data from users during the onboarding process (“Onboarding Data”). This data includes the pages viewed by the user, whether the user clicks the “Get started” link to begin completing the questionnaire, whether the user responds to any of the questionnaire prompts or data provided by the Organization.

Account Registration Data: Journey Nudge, Inc. collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number (“Account Registration Data”). Journey Nudge, Inc. also assigns each user (including Coaches) who creates a Journey Nudge, Inc. account an anonymized, randomly generated client ID.

Transaction Data: Journey Nudge collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for Journey Nudge services, signed up for Journey Nudge’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for Journey Nudge’s services (“Transaction Data”).

Login Data: Journey Nudge collects, uses, and stores data regarding logins to Journey Nudge’s Tool by registered users (including Organizations or Coaches) and activity conducted during that log in such as when a user logs in, the number of messages received or sent through Journey Nudge’s website or app during that log in, and whether a user has been assigned, started, or completed a Coaching goal (“Login Data”). Login Data does not include the content of any messages sent or received by users or the content of any Coaching goals.

Coaching Session Data: Journey Nudge collects, uses, and stores certain general data regarding user Coaching sessions such as whether a live session has been scheduled by the user, whether a Coach or user joins a scheduled session, when a Coaching session began and ended, and whether a Coaching session was canceled or re-schedule, and data that the end user wishes to have inform their profile and message schedule.

User Data: Journey Nudge collects, uses, and stores certain data from users that have signed up for Journey Nudge’s services such as a user’s self-reported name or nickname, age, e-mail address, phone number, role, level, goals, psychometrics and emergency contact information (“User Data”).

Coach Data: In order to credential, recredential, run checks and pay Coaches, Journey Nudge collects, uses, and stores certain data from Coaches. This data includes information such as the Coach’s name, e-mail address, and phone number, address, ICF number (if applicable), NPI number (if applicable), BCC number (if applicable), CAQH number (if applicable) and education and job history (“Coach Data”).

Communications Data: Journey Nudge collects, uses, and stores communications between users and Coaches on the Tool, and communications between users and Journey Nudge’s customer service team (“Communications Data”).

Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.

Purposes for Which Information is Used

We may use the information we collect for one or more of the following purposes:

Communication with you

• To contact you or provide you with information, alerts and suggestions that are related to the Tool.
• To verify your identity.
• To complete an activity you requested, such as register for the Tool or obtain more information.
• To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

Delivery of services to you

• To create your account on our Tool and let you log in to your account and use the Tool.
• To manage your account, provide you with customer support, and ensure you are receiving quality service.
• For billing and transaction processing purposes.
• To match users with Coaches and facilitate Journey Nudge Services.
• To provide, support, personalize, and develop our Tool and the Coach Services.

Administration and improvement of services

• To supervise, administer and monitor the Tool.
• To measure and improve the quality, effectiveness and delivery of our services

Compliance with law

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.

Other uses with consent

• Any other purpose with your consent.

Purposes for Which Information is Disclosed to Third Parties

Information about you or your organization will not be disclosed to third parties for one or more of the following purposes:

For business purposes and advertising: We may share a user’s information with a Coach and a Coach’s information with a user only as necessary for facilitating the Coach Services. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.

With your direction or consent: We may share your information with third parties if you request or direct us to do so.

With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group.

Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.

In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.

For other business reasons: We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Tool and our users.

Note that if you make any information publicly available on the Tool, anyone may see and use such information.

Opting out of Marketing Communication

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.

Cookies and Web Beacons

Like many websites, we use “cookies” and “web beacons” (also known as pixels) to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. We collect cookies that are necessary for the Tool to function, cookies that enhance the Tool’s performance, and cookies used for third-party tracking. A “web beacon” is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.

Use of Cookies, Web Beacons, and Similar Technology for Analytics

We may use third party cookies for the purposes of web analytics, attribution, and error management. Our Tool may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on television, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Tool.

Our Tool also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Tool usage.

Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks

You and others may see certain ads for our services or for the Tool on other websites because we participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different Tools, including social media websites.

Social and General Information Tools

We use several publicly available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

Phishing

Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).3. Links

The Tool may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third-party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services, and we do not have control over their privacy policies and terms of use.

Security of Information

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, state laws, and regulations regarding data privacy.

Service Providers

We may employ third party companies and individuals to facilitate our Tool, to perform certain tasks which are related to the Tool, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Tool is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Coaches may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.

Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Tool.

Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the “Contact” link at the bottom of any page on our website: Journeynudge.com